"CBF has only briefly reviewed the Virginia draft WIP, having received it on Tuesday, September 7th. We will be conducting a more thorough assessment and providing comment during the public comment period.

"The WIP is Virginia's opportunity to define how it will implement a pollution diet for its tidal rivers and the Chesapeake Bay. Upon initial examination, we have serious concerns about the WIP's lack of details. Absent dramatic changes, we ask EPA to consider, now, what actions it must take to ensure Virginia will accomplish its share of needed pollution reductions.

"While there are some good proposals in the WIP—to offset pollution from future growth, to offer tax incentives to farmers to use conservation practices—the document is stunningly deficient on how the Commonwealth will implement many of these proposals. In particular, the WIP does not specify how Virginia will reduce nonpoint runoff pollution from farms and urban areas. Further, it appears to fail to meet the James River's 2025 pollution reduction goals or distribute pollution reductions equitably among the river's stakeholders—contrary to the document's preamble.

"Rather than a draft roadmap on how Virginia intends to restore clean water to our rivers and the Bay, the WIP is replete with proposals to "investigate," "explore," and "consider" future actions. It lacks a commitment to pursue the additional legislation, funding, incentives, or other steps necessary to carry out the initiatives proposed in the WIP. There simply is too little information in the WIP to conclude it will achieve real results.

"It is critical to remember that the WIP is not only about our water quality; it is about our economy. Reducing water pollution supports the Commonwealth's multi-billion dollar fishing and tourism industries, creates jobs installing pollution reduction technologies on farms and in our cities, prevents future impacts on property values and public health, and avoids further passing the burden to citizens via increased utility costs resulting from polluted waters.

"Recent reports show underwater grasses in the Potomac River recovering following significant mandated reductions in nitrogen pollution from the Blue Plains sewage treatment plant, and streams in the Shenandoah Valley removed from the federal "dirty waters" list after implementation of detailed cleanup plans. These successes demonstrate that improvements in water quality will occur if robust, comprehensive cleanup plans are implemented aggressively. This same level of plan specificity followed by action is now needed in Virginia's WIP if we are to realize clean water across the region."

The Chesapeake Bay Foundation will be commenting in detail about the draft WIP during the public comment period, which runs from September 24 through November 8.

For more information on the Watershed Implementation Plan and Chesapeake Bay TMDL, go to cbf.org/biggestfight.